Start A New Page (“SANP”, “we” or “us”) is committed to protecting your privacy – in
this privacy policy (“this Policy”), we set out how we collect your personal data, how we
use it, and what rights and choices you have in relation to the personal data we hold and
process.
This Policy is separate and in addition to the terms and conditions of use of our website;
where applicable, please refer to the terms and conditions of use for further details.
Who decides why and how we process your personal data?
SANP determines why and how we process your personal data. In each case, your
personal data will controlled by SANP which you have given instructions to, or with
which you are otherwise dealing with or receiving communications from.
What personal data might we collect?
We collect different types of personal data for different reasons – this may include:
Contact information: Information such as your legal name, occupation, job title, postal
address, residential home address where you provide this to us, business address,
telephone number, mobile number, fax number and email address.
Personal details: information such as your age, date of marriage, location of marriage,
your spouse’s legal name and his/her residential address, your child(ren) particulars such
as his/her/their age, school attending and residential home address.
Payment data: Data necessary for us to process payments and implement fraud prevention
measures, including credit / debit card numbers, security code numbers and other such
relevant billing details.
Compliance details: Information we are legally required to collect for compliance
purposes, such as ‘know your client’ information, details relevant to international
sanctions and restrictive measures and information about relevant and significant
litigation, which may impact our ability to act.
Preferences: Information about your preferences, where it is relevant to the services we
provide.
Publicly available information: Information collected from publicly available resources,
including but not limited to information collected from databases we use to carry out
compliance checks or credit rating agencies.
Details for events: In some cases, we may collect information about you and your spouse,
which may include sensitive information in relation to your marriage and status and
conditions of your marriage for the purpose of tailoring our services meeting to your
needs. The processing of such data is based entirely on your consent – in the event that
you do not want us to maintain such data, we may not be able to take the necessary steps
to assist your case.
When do we collect your personal data?
We may collect personal data about you in various cases, such as for example:
When you or your spouse seek our services – i.e. automated divorce documents
generation or use any of our online services;
When you make an enquiry through our website, in person, over email or over the
telephone;
When you attend a SANP seminar or other events we may organise, or sign up to receive
communications from us, including training;
In some circumstances, we may collect personal data about you from third parties – for
example, we may collect personal data from your spouse or from whom you have
dealings including your banker, government agencies, a credit reporting agency, an
information or service provider or from a publicly available record.
How will we use your personal data?
We will use your personal data for the following purposes (Permitted Purposes):
To provide guidance and or other services or things you may have requested, including
online or technology services or solutions, as instructed or requested by you;
To manage and administer your business relationship with us, including processing
payments, accounting, auditing, billing and collection or support services;
For compliance with our legal obligations (such as record keeping obligations),
compliance screening or recording obligations (such as under antitrust laws, export
controls, trade sanction and embargo laws, for anti-money laundering, financial and
credit check and fraud and crime prevention and detection purposes), which may include
automated checks of your contact data or other information you provide about your
identity against applicable sanctioned-party lists and contacting you to confirm your
identity in case of a potential match or recording interaction with you which may be
relevant for compliance purposes;
To analyse and improve our services and communications to you;
To protect the security of and managing access to our website/servers, IT and
communication systems, online platforms, websites and other systems, preventing and to
detect security threats, fraud or other criminal or malicious activities;
For insurance purposes;
To monitor and assess compliance with our policies and standards;
To comply with our legal and regulatory obligations and requests anywhere in the world,
including reporting to and/or being audited by national and international regulatory, law
enforcement and tax reporting bodies;
To communicate with you through the channels you have approved to keep you up to
date on the latest developments, announcements, and other information about our
services, products and technologies – including client briefings, newsletters and other
information – as well as events and projects we may organize;
To comply with court orders and exercises and/or defend our legal rights; and
For any purpose related and/or ancillary to any of the above or any other purpose for
which your personal data was provided to us.
Where you have expressly given us your consent, we may process your personal data also
for the following purposes:
For customer surveys, marketing campaigns, market analysis, sweepstakes, contests or
other promotional activities or events; or
To collect information about your preferences to create a user profile to personalize and
foster the quality of our communication and interaction with you (for example, by way of
newsletter tracking or website analytics).
With regard to newsletters, legal updates and other general communications, we will –
where legally required – only provide you with such information if you have opted in.
You have the opportunity to opt out of receiving such communications at any time. We
will not use your personal data for taking any automated decisions affecting you or
creating profiles other than described above.
Depending on for which of the above Permitted Purposes we use your personal data, we
may process your personal data on one or more of the following legal grounds:
Because processing is necessary for the performance of a your instructions;
To comply with our legal obligations (e.g. to keep records for tax purposes); or
Because processing is necessary for purposes of our legitimate interest or those of any
third party recipients that receive your personal data, provided that such interests are not
overridden by your interests or fundamental rights and freedoms.
How will we share your personal data?
We may share your personal data in the following circumstances:
If necessary, we may disclose your personal data to:
Other legal specialists (including mediators), solicitors, counsellor, consultants or experts
engaged in your matter; or
If we have collected your personal data in the course of providing services to any of our
clients, we may disclose it to that client, and where permitted by law to others for the
purpose of providing those services;
We may disclose your contact details on a confidential basis to third parties for the
purposes of collecting your feedback on the firm’s service provision, to help us measure
our performance and to improve and promote our services;
We may share your personal data with companies providing services for money
laundering checks, credit risk reduction and other fraud and crime prevention purposes
and companies providing similar services, including financial institutions, credit
reference agencies and regulatory bodies with whom such personal data is shared;
We may share your personal data with any third party to whom we assign or novate any
of our rights or obligations;
We may share your personal data with courts, law enforcement authorities, regulators or
attorneys or other parties where it is reasonably necessary for providing services such as
generating an appropriate documents, or for the purposes of a confidential alternative
dispute resolution process;
We may also instruct service providers within or outside SANP, domestically or abroad,
e.g. shared service centres, to process personal data for the Permitted Purposes on our
behalf and in accordance with our instructions only. SANP will retain control over and
will remain fully responsible for your personal data and will use appropriate safeguards
as required by applicable law to ensure the integrity and security of your personal data
when engaging such service providers;
We may also use aggregated personal data and statistics for the purpose of monitoring
website usage in order to help us develop our website and our services.
We will otherwise only disclose your personal data when you direct us or give us
permission to do so, when we are required by applicable law or regulations or judicial or
official request to do so, or as required to investigate actual or suspected fraudulent or
criminal activities.
Can you refuse to share your personal data with us?
In general, we receive your personal data where you provide this on a voluntary basis,
and there will typically be no detrimental effect for you if you wish not to provide this or
otherwise withhold your consent for it to be processed. However, there are certain cases
where we will unfortunately be unable to act without receiving such data, for example
where we need to carry out legally required compliance screening or require such data to
process your instructions or orders, or otherwise to provide you with our online services
or communications.
Where it is not possible for us to provide you with what you request without the relevant
personal data, we will let you know accordingly.
How do we keep your personal data safe?
We take appropriate technical and organisational measures to keep your personal data
confidential and secure, in accordance with our internal policies and procedures regarding
storage of, access to and disclosure of personal data. We may keep your personal data in
our electronic systems, in the systems of our contractors, or in paper files.
Personal data we receive from you about other people
Where you provide us with the personal data of other people, such as your spouse and
child(ren) or other persons you may have dealings with, you must ensure that you are
entitled to disclose that personal data to us and furthermore that, without being required
to take further steps, we can collect, use and disclose that data in the manner described in
this Policy. More specifically, you must ensure that the individual whose personal data
you are sharing with us is aware of the matters discussed in this Policy, as these are
relevant to that individual, including our identity, how to get in touch with us, the
purposes for which we collect data, our disclosure practices, and the rights of the
individual in relation to our holding of the data.
Transfers of personal data abroad
SANP is active across the world and this means that we may transfer your personal data
abroad if required to do so for the Permitted Purposes. In certain cases, this may include
transferring data to countries which do not offer the same level of protection as the laws
of your country (such as for example the data protection legislation of the EU/EEA).
When making such transfers, we will ensure that they are subject to appropriate
safeguards in accordance with the General Data Protection Regulation (Regulation
2016/679) or other relevant data protection legislation. This may include entering into the
EU Commission’s Standard Contractual Clauses. Please get in touch with our Data
Protection Officer at info@startnewpage.com if you wish to obtain further information
on the appropriate safeguards which we are adhering to.
All entities and offices within SANP will ensure an adequate level of protection for your
personal data at all times.
How long do we keep your personal data?
We delete your personal data once it is no longer reasonably necessary for us to keep it
for the Permitted Purposes, or, where we have relied on your consent to keep your
personal data, once you withdraw your consent for us to do so, and we are not otherwise
legally permitted or required to keep the data. Importantly, SANP will keep your
personal data as necessary for the purposes of assessing your case and/or generating the
appropriate documents for divorce purpose.
In determining the appropriate retention period for personal data we consider such factors
as the nature of the information, the purposes for which the data is retained, appropriate
security measures, relevant technical constraints and applicable legal requirements.
Please contact us if you want further information about our record retention policy.
What rights do you have?
Subject to certain conditions under applicable legislation, you have the right to:
request a copy of the personal data which we hold about you;
have any inaccurate data we hold about you corrected;
object or restrict our use of your personal data;
submit a complaint if you have concerns about the way in which we are handling your
data.
To do any of the above, please contact us at info@startnewpage.com To enable us to
process your request, we may require that you provide us with proof of your identity,
such as by providing us with a copy of a valid form of identification – this is to ensure
that we appropriately protect the personal data we hold from unauthorized access requests
and comply with our security obligations.
We may charge you a reasonable administrative fee for any unreasonable or excessive
requests we may receive, and for any additional copies of the data you may request.
In relation to complaints, we will promptly respond to your requests and complaints. In
the event that you are unhappy with our response, you may submit a complaint to the
relevant privacy regulator. We can provide you with the details of the relevant regulator
upon request.
Correcting and updating your personal data
Where any personal data you have provided us with has changed, or where you believe
the personal data we hold is inaccurate, please let us know at info@startnewpage.com.
We cannot be responsible for any loss that may arise due to us having any inaccurate,
incomplete, inauthentic or otherwise deficient personal data which you have provided to
us. Please also let us know if you wish to withdraw any request.
Get in touch
We would be happy to hear your views about our website and this Policy – please let us
know any questions, comments or clarifications you may have at info@startnewpage.com
or send us a letter to our Data Protection Officer, Lion Rock Tech Limited of Office B,
5/F., Centre Mark II, 305-313 Queen’s Road Central, Hong Kong.
Changes to our Privacy Policy
This Policy was last updated on 18 March 2024. We have the right to update the contents
of this Policy from time to time to reflect any changes in the way in which we process
your personal data or to reflect legal requirements as these may change. In case of
updates, we will post the revised Privacy Policy on our website. Changes will take effect
as soon as the revised version is made available on our websites.